Consumer Finance in Alabama—the View from the Regulator

The Alabama Installment Lenders Association held its 2023 Legislative Meeting & Reception in Montgomery last week. This annual meeting traditionally coincides with the start of the Regular Legislative Session. Prior to the Reception, Scott Corscadden, Alabama Banking Department Supervisor addressed the meeting.

The Supervisor first reviewed some staffing changes at the Department. Anne Gunter has returned as a divisional attorney and Lynne Windham is retiring as of June 1st. Lynne has served the Department as Assistant Supervisor over Loan Examinations. Tricia Kirby will be replacing Lynne. The Department is moving to have the examination staff become certified or accredited pursuant to the guidelines or rules of the Conference of State Bank Supervisors.

He next reported on the continuing efforts of the Department to upgrade its data base to allow licensees to make routine revisions electronically. Corscadden then reported on the number of licensed entity locations supervised by the Department.  There are currently 16,303 total licensees, of which 3524 are either Small Loan Act or Mini-Code licensees. These numbers are slightly down. Corscadden reported that the Department conducted 2791 examinations in 2022, and normally expects to conduct 3,000 per year.  There was a general discussion of multi-state license registration and examination. These coordinated exams with other states and the CFPB continue to become more the norm.

Mr. Corscadden addressed the Department’s continuing review of cyber security issues.  He also discussed the shifting of payday lenders to Small Loan Act licensees in Alabama. Advance America is an example. He also discussed the “buy now, pay later” trend and its impact on licensees. Finally, Supervisor Corscadden reported that the Small Loan Act and Mini-Code licensees continue to handle complaints in an exemplary fashion.

-Maurice L. Shevin

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